Farish v. Commissioner
United States Tax Court
In prior proceedings between respondent and petitioner, Libbie Rice Farish, and W. S. Farish, deceased, involving their respective gift taxes for 1934 and 1935, their rights to certain exclusions and exemptions with respect to transfers made to trusts in 1933, 1934, and 1935 were litigated before this Court and, upon the concession of the respondent, were given effect by our judgments.
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In prior proceedings between respondent and petitioner, Libbie Rice Farish, and W. S. Farish, deceased, involving their respective gift taxes for 1934 and 1935, their rights to certain exclusions and exemptions with respect to transfers made to trusts in 1933, 1934, and 1935 were litigated before this Court and, upon the concession of the respondent, were given effect by our judgments. Held: (1) These judgments estop the respondent from denying those exclusions in the determination of gift taxes on transfers by the same donors to the same trusts in 1938 since the law does not require that…
1Opinion of the Court
OPINION.
Leech, Judge'.
These consolidated cases involve gift tax deficiencies for the calendar year 1938 as follows: Libbie Rice Farish, in the amount of $3,860.98; estate of W. S. Farish, in the amount of $4,875.
The sole question involved is whether respondent erroneously computed net prior gifts in determining the gift tax liability of the petitioners for 1938.1
The cases were submitted on stipulated facts which we adopt as our findings of fact.
During the period involved, prior thereto, and until November 29,. 1942, the petitioner, Libbie Rice Farish, and W. S. Farish were husband and wife,…
2Cases cited25 opinions
- Cromwell v. County of SacSupreme Court of the United States · 1877
- Southern Pacific Railroad v. United StatesSupreme Court of the United States · 1897
- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- Hart Steel Co. v. Railroad Supply Co.Supreme Court of the United States · 1917
- United States v. MoserSupreme Court of the United States · 1924
20 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Fairmont Aluminum Co. v. CommissionerUnited States Tax Court · 1954
- Riter v. CommissionerUnited States Tax Court · 1944
- Kleberg v. CommissionerUnited States Tax Court · 1943
- C. D. Johnson Lumber Corp. v. CommissionerUnited States Tax Court · 1951
- Pitcairn v. CommissionerUnited States Tax Court · 1944
9 more not listed; retrieve them via the Exa API.